The CPT reiterates, once more, its recommendation that foreign nationals deprived of their liberty under immigration legislation should be systematically and fully informed of their rights, their legal situation (including the grounds for detention) and the procedure applicable to them as from the very outset of their deprivation of liberty, and with the assistance of a qualified interpreter, if necessary. Further, all detained persons should be systematically provided with a copy of the leaflet setting out this information in a language and manner they can understand. Moreover, detained foreign nationals should be provided with regular information and updates on their situation and the status of their procedure, on a case-by-case basis. 38. The delegation also found that no effective complaints system was operating in any of the detention establishments visited. Some rudimentary elements of an internal complaints system were in place in some pre-removal detention centres, such as Corinth PRDC, where complaint forms were distributed to detained persons. However, these forms were collected by the duty police officers, and persons complained that they never received feedback to their written complaints or requests. Detained persons in all the PRDCs stated that they were also not aware of external complaints mechanisms. 39. The CPT considers that effective complaints procedures are basic safeguards against ill-treatment in immigration detention facilities. Foreign nationals deprived of their liberty should have avenues to complaint open to them, both internally and externally, and in a language they understand, and they should be entitled to confidential access to an appropriate complaints authority. This should notably be ensured by effectively informing detained persons about the available means of complaint, by ensuring that a proper record is maintained of every complaint made, and that those detained persons who make them receive, within a reasonable time, a reasoned answer. To this end, confidential complaints boxes should be placed in the detention areas and only opened by dedicated staff responsible for the internal complaints process. The CPT recommends that the Greek authorities take the necessary steps to introduce an effective internal complaints system in all establishments where foreign nationals are deprived of their liberty under immigration legislation. In addition, persons in immigration detention should be informed about the available avenues of external complaint, taking into account the above remarks. 40. The CPT wishes to recall again that, in the same way as other categories of detained persons, foreign nationals deprived of their liberty under immigration legislation should, from the outset of their deprivation of liberty, enjoy three basic rights that are fundamental safeguards against ill-treatment, namely the rights to notify a relative or third party of their detention, to have access to a lawyer and to a doctor. The CPT once again found that these fundamental safeguards against ill-treatment, for the most part, do not apply from the very outset of a foreign national’s deprivation of liberty and, more generally, were not operating properly in practice, despite the existence of clear rules.12 Further, in some of the pre-removal centres visited, there was no dedicated register for the recording of these safeguards. 41. According to the information gathered during the visit, the right to notify a family member or third person was respected in some police stations visited, where persons could make a telephone call. However, several detained foreign nationals met by the delegation who were – or had recently been – in police custody stated that they had not been granted promptly the right to notify a close relative, or third party of their choice, of their detention (see paragraph 43, as regards contacts with the outside world). 12. See the report on the CPT’s 2013 visit (CPT/Inf (2014) 26), paragraphs 27-32, where these issues were clearly laid out. The findings from the Committees’ visits carried out in 2015, 2016, 2018 and 2020 all found that there had been no improvement. 14

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